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<br />3. Brief and plain statement of the reasons Trout Unlimited seeks Party status: <br /> <br />TU emphasizes that it supports the CWCB's efforts to secure adequate in-stream <br />flows in this case. . TU submits this Application for Party Status in order to ensure <br />its participation in all and any negotiations concerning the quantification of the in- <br />stream flows at issue herein, and to ensure its ability to submit, for the record, <br />technical evidence, technical witnesses or file legal memoranda. <br /> <br />4. Contested facts, the matters which Trout Unlimited claims should be decided, and <br />a general description of data Trout Unlimited intends to present to the Board: <br /> <br />a. TU will rely on CWCB staff and Bureau of Land Management ("BLM") <br />reports and memos about the subject recommendations, the Division of <br />Wildlife data analysis referenced in the BLM recommendation, all <br />attachments and appendices to the aforementioned documents, information <br />in TU's possession and available from TU's contractor, and any other <br />public information, such as stream gage records. <br /> <br />b. TU identifies the following contested facts and issues: <br /> <br />Whether or not the following CWCB staffiecommendation of 1.6 <br />~f;s (A~,.;l 1 A~n'130) '" 0 "fis ""r""1 May 3" "ud 0 2 c"o 'JT.wule <br />........ \.... ""p.U.l. ...=.. 1..1-' , ""1'.-' \,.I \.I.Y.Lay - J.J, oi:U . .1::; \. <br />I-March 31) is sufficient to preserve the environment ofthe San <br />Miguel River to a reasonable degree; <br /> <br />Whether or not the recommendation of the Bureau of Land <br />Management ("BLM") in the amounts of 4.25 cfs (April I-October <br />31) and 1.5 cfs (November I-March 31) is sufficient to preserve <br />the environment of the San Miguel River to a reasonabre degree; <br /> <br />Whether or not water is physically available to support <br />appropriations in the amounts and time periods recommended by <br />the CWCB staff and/or the BLM; <br /> <br />Whether or not appropriations in the amounts and time periods <br />recommended by the CWCB staff and/or the BLM would cause <br />injury to the water rights of others; and <br /> <br />Whether or not the issues raised in the March 23,2002 Notice to <br />Contest filed by Minion Hydrologic, Jon and Joanne Corzine, and <br />John and Victoria Irwin with regard to the Specie Creek ISF are <br />supported by evidence. <br /> <br />c. TU reserves the right to identify additional contested facts and issues, and <br />additional data and documents upon which it may rely as new information <br />becomes available. <br /> <br />-I <br />